Independent application of mind is essential for tax notices; AI-generated notices without it are legally unsustainable.

A tax show-cause notice must reflect the competent officer's independent examination of facts and application of mind. The notes state that preparing and issuing such a notice primarily through an artificial intelligence tool lacks statutory sanction where independent consideration is not demonstrated. An assertion that AI-generated references were inadvertently uploaded does not establish the required exercise of jurisdiction. On the stated analysis, the AI-based notice and consequential proceedings were treated as legally unsustainable and quashed.

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Issues: Whether a tax show-cause notice prepared and issued primarily using an artificial intelligence tool, without demonstrated independent application of mind by the competent officer, is legally sustainable.

Analysis: The statutory scheme requires the competent authority to examine the case facts and independently apply mind before issuing a show-cause notice. Use of an artificial intelligence tool for preparation and issuance of the notice lacked statutory sanction; the Department's assertion that the AI references were inadvertently uploaded did not establish the required independent consideration.

Conclusion: The AI-based show-cause notice and consequential proceedings were held unsustainable in law and quashed, in favour of the assessee.

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